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Sheprd Inc. Privacy Policy

Last modified April 7, 2017

This Privacy Policy relates to information collected online and offline by Sheprd Inc. (“Sheprd” "we" or “us” or “our”) through your use of the Sheprd iPhone app (the “App”), the website sheprd.us and any subdomains (the “Site”), and the services, features, and information available on the App and the Site (together with the App, the Site, associated and successor websites and mobile applications, features, information, and services, or any part thereof, the “Service”). This Privacy Policy is incorporated into, a part of, and governed by the Sheprd Terms of Use. Capitalized terms used in this Privacy Policy without definition have the meaning given to them in the Sheprd Terms of Use.

For clarification, although the Service is intended to provide Rides for children, use of the App and the Site is restricted to adults who are the age of majority (18 in most states). Parents and legal guardians of children may provide information about their children, but we do not knowingly collect personal information from anyone under the age of 13 or knowingly allows such persons to register for the Service. As used herein, “you” and “your” mean a user of the Service (including without limitation, a Site or App visitor as well as individuals who have registered), and for clarification, when you, as a parent or guardian, provide information about your child, we treat such information as your information.

You should carefully read this Privacy Policy. By using the Service, you are signifying your acceptance of this Privacy Policy, both on behalf of yourself and on behalf of any minor whose information you provide or for which you book a Ride. If you do not agree to this Privacy Policy, you may not use the Service.

As used in this Privacy Policy, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our affiliates within the United States or internationally.

This Privacy Policy serves to notify you of the following:

WHAT INFORMATION IS COLLECTED?

Depending on your use of the Service, we may collect two types of information: personally identifiable information and non-personally identifiable information.

Personally Identifiable Information

Personally identifiable information is information that identifies a person or can be used to identify or contact a person. Such information may include your name, address, e-mail address, telephone number, and billing and credit card information.

Non-Personally Identifiable Information

Non-personally identifiable information is information, any single item of which, by itself, cannot be used to identify or contact a person, including demographic information (such as age, profession, grade in school, gender, current location, pick up and drop off locations and times, health conditions, zip code, birth date, or year of birth), IP addresses, browser types, unique device identifiers, device types, requested URL, referring URL, browser language, the pages you view, the date and time of your visit, domain names, and statistical data involving the use of the Service. Certain non-personally identifiable information may be considered a part of your personally identifiable information if it were combined with other identifiers (for example, combining your zip code with your street address) in a way that enables you to be identified. However, the same pieces of information are considered non-personally identifiable information when they are taken alone or combined only with other non-personally identifiable information (for example, your viewing preferences).

WHERE AND WHEN IS INFORMATION COLLECTED (INCLUDING THROUGH THE USE OF COOKIES AND ACTION TAGS)?

We will collect personally identifiable information that you submit to us. We may also receive personally identifiable information about you and your Passengers from third parties, including our Partners and Drivers and those providing credit and debit card authorization and fraud screening services as part of your use of the Service.

Registering to Use the Service and in the Course of Using the Service.

You may be required to establish an account in order to take advantage of certain features of the Service. If you wish to establish an account you will be required to provide us with information (including personally identifiable information and non-personally identifiable information) such as name, postal address, e-mail address, telephone number, Passenger name, Passenger health conditions, Passenger birth date, Passenger telephone number, Passenger gender, Passenger photo, Passenger emergency contact name and telephone number, and credit card and billing information. And, if you book Rides through the Service, you will be required to provide us with further information, such as pick up and drop off dates, times, and locations and the designated Passengers for such Rides. We may also receive personally identifiable information about you from third parties, including those providing credit and debit card authorization and fraud screening services as part of the registration process and our Partners and Drivers. In addition, we may obtain your personally identifiable information from you if you identify yourself to us by sending us an e-mail with questions or comments.

If you choose to access the Service using the Facebook Login feature, you are providing us with access to information, data, and attributes in your Facebook public profile, your email address and verified phone number, which we use to assist in log-on procedures and authentication of users.

Information Collected During Rides

We collect precise location data concerning all Rides through the Service. We also video and audio record all Rides using inward and outward facing dashboard cameras that gather both internal views and sound recordings of the vehicle’s passenger area (“Internal Video”) as well as external views and sound recordings (“External Video”). Both Internal Video and External Video may include images of Passengers.

Cookies and Action Tags.

We may collect non-personally identifiable information passively using “cookies” and “action tags.”

“Cookies” are small text files that can be placed on your computer or mobile device in order to identify your Web browser and the activities of your computer on the Service and other websites. Cookies can be used to personalize your experience on the Service (such as dynamically generating content on webpages specifically designed for you), to assist you in using the Service (such as saving time by not having to reenter your name each time you use the Service), to allow us to statistically monitor how you are using the Service to help us improve our offerings, and to target certain advertisements to your browser which may be of interest to you or to determine the popularity of certain content.

In addition to cookies that we may place on your computer or mobile device, cookies might also be placed on your computer or mobile device by third parties that we use to display or serve advertisements or to collect non-personally identifiable information in order to provide advertising-related services as well as by third parties providing analytical and other services related to the Service. In the course of providing services and serving advertisements, such third parties could place or recognize unique cookies on your browser.

You do not have to accept cookies to use the Service. Although most browsers are initially set to accept cookies, you may reset your browser to notify you when you receive a cookie or to reject cookies generally. Most browsers offer instructions on how to do so in the "Help" section of the toolbar. However, if you reject cookies, certain features or resources of the Service may not work properly or at all and you may experience some loss of convenience.

For the avoidance of doubt, this Service uses third-party service platforms (including to help analyze how users use the Service, to provide more personalized Services to you, and to facilitate online form submission processes). These third-party service platforms may place cookies on your computer or mobile device. If you would like to disable "third party" cookies, you may be able to turn them off by going to the third party's website.

Here is a link to the main third-party platform we use:

www.google.com/policies/privacy

"Action tags," also known as web beacons or gif tags, are a web technology used to help track website usage information, such as how many times a specific page has been viewed. Action tags are invisible to you, and any portion of the Service, including advertisements, or e-mail sent on our behalf, may contain action tags.

By using cookies and action tags together, we are able to gain valuable information to improve the Service and measure the effectiveness of our advertising and marketing.

Finally, you should be aware that advertisers and other third parties may use their own cookies or action tags when you click on their advertisement or a link to their websites or services on or from the Service. This Privacy Policy does not govern the use of cookies or action tags or the use of your information by such third-party websites or services or providers of third-party advertising.

Log Files.

We also collect non-personally identifiable information through our Internet log files, which record data such as user IP addresses, browser types, domain names, and other anonymous statistical data involving the use of the Service. This information may be used to analyze trends, to administer the Service, to monitor the use of the Service, and to gather general demographic information. We may link this information to personally identifiable information for these and other purposes such as personalizing your experience on the Service and evaluating the Service in general.

DOES SHEPRD COLLECT INFORMATION FROM CHILDREN UNDER 13 YEARS OF AGE?

We are committed to protecting the privacy of children. Although the Service is intended to facilitate transportation of children, use of the Service is restricted to adults who are the age of majority. The Service is not designed for or directed to children under the age of 13. Parents and legal guardians of children may provide information about their children, but we do not knowingly collect personal information from anyone under the age of 13 or knowingly allows such persons to register for the Service. By providing information to Sheprd or through the Service, you represent that you are the age of majority. If you are under the age of majority, please do not attempt to register for the Services or send any information about yourself to us.

WHAT DOES SHEPRD DO WITH THE INFORMATION IT COLLECTS?

In general, we use the information collected to provide the Service to you and process your transactions, to help us understand who uses the Service, for internal operations such as operating and improving the Service, to contact you for customer service and billing purposes, to facilitate the delivery of advertising, and, unless you opt out, so that we (on behalf of Sheprd and certain third parties, including our Partners) can contact you about products and services that may be of interest to you.

We may use your information to send you a welcoming e-mail that may confirm your user name and password. Unless you opt out, we (on behalf of Sheprd and certain third parties, including our Partners) may send you electronic newsletters, contact you about the Service, products, services, information and news that may be of interest to you, and provide you with targeted feedback. If you no longer desire to receive these communications, we will provide you with the option to change your preferences. If you identify yourself to us by sending us an e-mail with questions or comments, we may use your information (including personally identifiable information) to respond to your questions or comments, and we may file your questions or comments (with your information) for future reference. We may also use the information collected to send announcements and updates regarding the Service or, if applicable, about your billing account status. You will not be able to unsubscribe from these Service announcements and updates as they contain important information relevant to your use of the Service.

We may also use the information gathered to perform statistical analysis of user behavior or to evaluate and improve the Service. We may link some of this information to personally identifiable information for internal purposes or to improve your experience with the Service

WHEN DOES SHEPRD DISCLOSE INFORMATION TO THIRD PARTIES?

Except as set forth in this Privacy Policy or our Terms of Use or as specifically authorized by you, we will not disclose any information we gather from you through the Service.

Drivers.

We may share with our Drivers your information, including without limitation your name, telephone number, your booked Ride details (including pickup and drop off dates, times, and locations), the name and telephone number of your Passenger’s emergency contact, your Passenger’s name, gender, age, telephone number, photo, and health conditions, all to the extent reasonable in order to safely provide Rides and deliver and improve the Service. As an example, we may not provide a Driver with a Passenger’s full name and cell phone number in all circumstances but we will do so whenever when believe it reasonable to further the safe provision of Rides and deliver and improve the Service.

Partners.

We may share with our Partners your information, including without limitation your name, your booked Ride details (including pickup and drop off dates, times, and locations), the name of your Passenger’s emergency contact, and your Passenger’s name, all to the extent reasonable in order to safely provide Rides and deliver and improve the Service.

Addressing Complaints and Other Events.

We may share your information, such as Ride details and location information and images of Passengers contained in Internal Video and External Video, with third parties, including without limitation, Drivers, Partners, and the parents of other Passengers, on a limited basis to the extent necessary to address complaints involving the Service and particular Rides and to evaluate events occurring during Rides. When practicable, we will provide Passenger anonymity when sharing Internal Video and External Video. Please note in particular that if there is an event or accident in connection with a Ride, we may share the External Video with our dashboard camera service provider.

Laws and Legal Rights.

We may disclose your information (including personally identifiable information) if we believe in good faith that we are required to do so in order to comply with an applicable statute, regulation, rule or law, a subpoena, a search warrant, a court or regulatory order, or other valid legal process. We may disclose personally identifiable information in special circumstances when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating the Sheprd Terms of Use, to detect fraud, for assistance with a delinquent account, or to protect the safety and/or security of our users, Passengers, Drivers, Partners, the Service or the general public.

Third Parties Generally.

We may provide to third parties non-personally identifiable information, including where such information is combined with similar information of other users of the Service. For example, we might inform third parties regarding the number of unique users who use the Service, the demographic breakdown of our users of the Service, or the products and/or services purchased using the Service and the vendors of such products and services. In addition to the above, when users use our Service, third parties (including without limitation third-party advertisers, analytics service providers, and commercial partners) may directly collect personally identifiable and non-personally identifiable information about our users’ online activities over time and across different websites. The third parties to which we may provide or who may independently directly collect personally identifiable and non-personally identifiable information may include analytics service providers, potential or actual advertisers, providers of advertising products or services (including vendors and website tracking services), online form service providers, merchants, affiliates and other actual or potential commercial partners, sponsors, licensees, researchers and other similar parties.

Please note in particular that the Service uses Google Analytics, including its data reporting features and Google Analytics Advertising Features. Information collected by Google Analytics includes but is not limited to web metrics. For information on how Google Analytics collects and processes data, please see the site “How Google uses data when you use our partners' sites or apps”, currently located at www.google.com/policies/privacy/partners/. For information on opting out of Google Analytics, we encourage you to visit Google’s website, including its list of currently available opt-out options presently located at https://tools.google.com/dlpage/gaoptout. Please note in particular that the Service uses. For information on Google Analytics’ currently available opt-out options, we encourage you to visit Google’s website.

Outside Contractors.

We may employ independent contractors, vendors and suppliers (collectively, "Outside Contractors") to provide specific services and products related to the Service, such as hosting and maintaining the Service, providing credit card processing and fraud screening, dashboard camera-related services, online form submission services, and developing applications for the Service. In the course of providing products or services to us, these Outside Contractors may have access to information collected through the Service, including your personally identifiable information, and in the case of our dashboard camera service provider, the External Video if there is an event or accident in connection with a Ride. To the extent that Outside Contractors have access to Personal Information (as defined below), we take steps to ascertain that such Outside Contractors use data security protocols that meet or exceed our own standards. As used in this Privacy Policy, “Personal Information” means your first name and last name or first initial and last name in combination with any one or more of the following that relate to you: (a) Social Security number; (b) driver’s license number or state-issued identification card number; or (c) financial account number, credit card number, or debit card number, with or without any required security code, access code, personal identification number or password, that would permit access to your financial account (but excluding information that is lawfully obtained from publicly available information, or from federal, state or local government records lawfully made available to the general public).

Sale of Business.

We reserve the right to transfer information to a third party in the event of a sale, merger or other transfer of all or substantially all of the assets of Sheprd or any of its Corporate Affiliates (as defined below), or that portion of Sheprd or any of its Corporate Affiliates to which the Service relates, or in the event that we discontinue our business or file a petition or have filed against us a petition in bankruptcy, reorganization or similar proceeding, provided that the third party agrees to adhere to the terms of this Privacy Policy.

Affiliates and Investors.

We may disclose your information (including personally identifiable information) to our Corporate Affiliates, investors, and potential investors. For purposes of this Privacy Policy: "Corporate Affiliate" means any person or entity which directly or indirectly controls, is controlled by or is under common control with Sheprd, whether by ownership or otherwise; and “control” means possessing, directly or indirectly, the power to direct or cause the direction of the management, policies or operations of an entity, whether through ownership of fifty percent (50%) or more of the voting securities, by contract or otherwise.

Our Service may provide you with access to other websites and services. This may include providing you with the ability to automatically post updates on Facebook and Twitter. Please be aware that we are not responsible for the privacy practices of any websites or services other than the Service. We encourage you to read the privacy policies or statements of each and every such website and service. This Privacy Policy applies solely to information collected by us through the Service.

IS THE INFORMATION COLLECTED THROUGH THE SERVICE SECURE?

We want your information (including personally identifiable information) to remain secure. We strive to provide transmission of your Personal Information from your computer or mobile device to our servers through techniques that are consistent with industry standards and to employ administrative, physical, and electronic measures designed to protect your Personal Information from unauthorized access. Notwithstanding the above, you should be aware that there is always some risk involved in transmitting information over the Internet. There is also some risk that others could find a way to thwart our security systems. As a result, while we strive to protect your information, we cannot ensure or warrant the security or privacy of any information you transmit to us, and you do so at your own risk.

COULD MY INFORMATION BE TRANSFERRED TO OTHER COUNTRIES?

Personally identifiable information collected on the Service may be transferred from time to time to our offices or personnel, or to third parties, located throughout the world, and the App and Site may be viewed and hosted anywhere in the world, including countries that may not have laws of general applicability regulating the use and transfer of such data. By using the Service and submitting such information on it, you voluntarily consent to the trans-border transfer and hosting of such information. If you are a user accessing the Service from a jurisdiction with laws or regulations governing personal data collection, use, and disclosure that differ from those of the United States, please be advised that all aspects of the Service are governed by the internal laws of the United States and the Commonwealth of Massachusetts, USA, regardless of your location.

WHAT CHOICES DO I HAVE REGARDING THE COLLECTION, DISCLOSURE AND DISTRIBUTION OF PERSONALLY IDENTIFIABLE INFORMATION?

Personally identifiable information collected on the Service may be transferred from time to time to our offices Except as otherwise described in this Privacy Policy or our Terms of Use, we will only use personally identifiable information for the purposes described above or as otherwise disclosed at the time we request such information from you. You must "opt in" and give us permission to use your personally identifiable information for any other purpose. You may also change your preference and "opt out" of receiving certain marketing communications from us by following the directions provided in association with the communication, or by contacting [email protected]

DO NOT TRACK

Personally identifiable information collected on the Service may be transferred from time to time to our offices The term “Do Not Track” refers to a HTTP header offered by certain web browsers to request that websites refrain from tracking the user. We take no action in response to Do Not Track requests.

CAN I UPDATE OR CORRECT MY PERSONALLY IDENTIFIABLE INFORMATION?

Personally identifiable information collected on the Service may be transferred from time to time to our offices You have the right to request the restriction of certain uses and disclosures of personally identifiable information as follows. You can (1) edit personally identifiable information related to your account directly in the App, (2) change your preferences with respect to communications and other information you receive from us, or (3) delete the personally identifiable information maintained about you on our systems (subject to the following paragraph), by closing your Sheprd account in the App or contacting [email protected]. Such updates, corrections, changes and deletions will have no effect on other information that we maintain, or information that we have provided to third parties in accordance with this Privacy Policy prior to such update, correction, change or deletion. To protect your privacy and security, we may take reasonable steps (such as requesting a unique password) to verify your identity before granting you profile access or making corrections. You are responsible for maintaining the secrecy of your unique password and account information at all times.

Personally identifiable information collected on the Service may be transferred from time to time to our offices You should be aware that it is not technologically possible to remove each and every record of the information you have provided to us from our system. The need to back up our systems to protect information from inadvertent loss means that a copy of your personally identifiable information may exist in a non-erasable form that will be difficult or impossible for us to locate. After receiving your request, we will use commercially reasonable efforts to update, correct, change, or delete, as appropriate, all personally identifiable information stored in databases we actively use and other readily searchable media as appropriate, as soon as and to the extent reasonably practicable.

HOW WILL I KNOW IF THERE ARE ANY CHANGES TO THIS PRIVACY POLICY?

We may revise this Privacy Policy from time to time. We will not make changes that result in significant additional uses or disclosures of your personally identifiable information without allowing you to “opt in” to such changes. We may also make non-significant changes to this Privacy Policy that generally will not significantly affect our use of your personally identifiable information, for which your opt-in is not required. We encourage you to check this page periodically for any changes. If any non-significant changes to this Privacy Policy are unacceptable to you, you must immediately contact us and, until the issue is resolved, stop using the Service. Your continued use of the Service following the posting of non-significant changes to this Privacy Policy constitutes your acceptance of those changes.

WHO DO I CONTACT IF I HAVE ANY PRIVACY QUESTIONS?

If you have any questions or comments about this Privacy Policy or feel that we are not abiding by the terms of this Privacy Policy, please contact our Privacy Agent in any of the following ways:

By e-mail:

[email protected]

By postal mail or courier:

Attn: Privacy Agent
Sheprd Inc.
361 Newbury St,
Boston, MA 02115

BY USING THE SERVICE, YOU SIGNIFY YOUR ACCEPTANCE OF THIS PRIVACY POLICY, BOTH ON BEHALF OF YOURSELF AND ON BEHALF OF ANY MINOR WHOSE INFORMATION YOU PROVIDE OR FOR WHICH YOU BOOK A RIDE. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, YOU MAY NOT USE THE SERVICE. CONTINUED USE OF THE SERVICE, FOLLOWING THE POSTING OF CHANGES TO THIS PRIVACY POLICY THAT DO NOT SIGNIFICANTLY AFFECT THE USE OR DISCLOSURE OF YOUR PERSONALLY IDENTIFIABLE INFORMATION, MEANS THAT YOU ACCEPT THOSE CHANGES.

Download the app

To book a ride, simply download the Sheprd app on your smartphone.